Saqib Kafeel v. CJDropshipping

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

52, SAC ¶¶ 1, 5, 9-24, 26-28.) Defendant now moves to dismiss the SAC on jurisdictional and other grounds,(seegenerallyR.54,Def.’sMot.toDismiss),andfor sanctions based on Kafeel's reliance on AI-hallucinated case citations and quotations in court filings, (R. 59, Def.’s Mot. for Sanctions). Analysis A. Motion to Dismiss *2 Defendant moves to dismiss the SAC under: (1) Rule 12(b)(1) for lack of subject matter jurisdiction; (2) Rule 12(b) (2)forfailuretoestablishpersonaljurisdiction;(3)Rule12(b) (6) for failure to state a claim; and (4) the doctrine of forum non conveniens pursuant to a forum selection clause included in the parties’ user agreement. (See generally R. 54, Def.’s Mot. to Dismiss.) 1. Rule 12(b)(6) The court turns first to Defendant's principal argument—that Kafeel has not sufficiently stated a Lanham Act claim. (R. SAQIB KAFEEL, Plaintiff, v. CJDROPSHIPPING, Defendant., Slip Copy (2026) 54, Def.’s Mot. to Dismiss at 1-5.) To survive a Rule 12(b)(6) motion, the complaint must assert a facially plausible claim andprovidefairnoticeofitsbasis.BellAtl.Corp.v.Twombly, 550 U.S. 544, 555 (2007). A claim is facially plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v.

Authorities cited in the passage: Rule 12(b)(1) · Rule 12(b) · Rule12(b) · Rule 12(b)(6)